On October 3, 2014, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) published a long-awaited proposed rule for implementing amendments to safe harbors under the Anti-kickback Statute and...more

Recently China’s National Development and Reform Commission (NDRC) imposed an RMB 353 million (USD 56.7 million) penalty against an international price-fixing cartel of LCD manufacturers, the largest the NDRC has ever imposed...more

On November 28, 2012, the Japan Fair Trade Commission (“JFTC”) published the findings of its 2012 survey of corporate compliance practices based on (i) responses from approximately 879 companies listed on the Tokyo Stock...more

John Hanson, a former FBI Agent and practicing forensic accountant, takes you inside of his mind and behind the numbers of a Ponzi Scheme to answer the universal question: "Where did all that money go?"
Based on actual...more

The Justice Department’s criminal antitrust enforcement program has had some major successes. In many respects, the Justice Department’s criminal antitrust program provides an example of what the FCPA criminal program may...more

The LIBOR “scandal” could have far-reaching implications for financial institutions in the United States and global markets. It is hard to know exactly how the issue will play out. The Department of Justice is definitely...more

Originally published in InsideCounsel.com on July 11, 2012.
The government increasingly has turned its focus abroad, to cross-border investigations and prosecutions, garnering major headlines in cases involving the Foreign...more

The Department of Justice (DOJ) and Federal Trade Commission (FTC) recently issued their Hart-Scott-Rodino (HSR) Annual Report, documenting a significant increase both in the number of transactions reported and the number...more

On July 2, the Serious Fraud Office (SFO) published a press release regarding the manipulation of the setting of the London Interbank Offered Rate (LIBOR).
In the press release, the SFO stated that it had been working...more

Who would have ever guessed that the largest corporate penalty paid in 2012 would be an OFAC enforcement action. The Justice Department has many major FCPA enforcement actions in the queue awaiting approval and public...more

There are a number of lengthy articles about antitrust compliance programs. This quick post will give you short answers to three questions: (i) why should you have a compliance program? (ii) what features should a program...more

IN THIS ISSUE:
- Industry Scorecard
Publishing: Although the case is civil rather than criminal, the U.S. Justice Department’s Antitrust Division (Division) launched a significant price-fixing lawsuit against...more

You have just received notice of a grand jury subpoena duces tecum from the Department of Justice Antitrust Division in connection with a price-fixing investigation. (The likelihood of doing so may be on the rise. In 2008,...more

On May 3, the U.S. DOJ announced that an executive of South Korean-based Hyosung Corporation agreed to plead guilty and to serve time in a U.S. prison for obstruction of justice charges in connection with an automated teller...more

Some industries have dodged anti-corruption industry sweeps. So far, the industry sweeps have focused on logistics, oil, pharmaceuticals and medical devices. The logistics industry has been a fertile source for other...more

On 16 March 2011, the UK government’s Department for Business, Innovation and Skills (BIS) launched a consultation proposing a number of reforms to the UK competition regime. After considering the responses on its proposals...more

Yesterday, the UK Government published its response to the consultation on competition reform. As widely expected, the Government has confirmed it will introduce a legislative proposal to merge the existing Competition...more

On 15 March, 2012, almost a year since a public consultation was launched, the UK Department of Business, Innovation and Skills (BIS) announced wide reaching changes to the UK competition regime. The reforms straddle almost...more

The Department of Justice is proud of its record on FCPA enforcement. They take credit whenever and wherever they can. They trumpet every settlement. They proudly proclaim that over half of last year’s criminal...more

A coalition of 80 institutional investors sent a letter to Congress last week in support of the Business Transparency on Trafficking and Slavery Act (HR 2759). As discussed previously, the proposed legislation would...more

On September 29, 2011, Ireland’s Minister for Jobs, Enterprise and Innovation, published a new competition bill (The Competition (Amendment) Bill 2011). This bill includes measures aimed to further enhance the Irish...more

Having the Federal Trade Commission – or any other government agency – initiate an action against you or your company may seem like very bad news. But it can get much worse. Sometimes, what starts as a civil action by a...more

Companies doing business in the People's Republic of China (“PRC”) have yet another path to potential criminal liability. On February 25, 2011, the PRC legislature passed 49 amendments to the PRC Criminal Law. One such...more